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Case 1:17-mc-00025-RWS Document 10-13 Filed 06/30/16 Page 1 of 3
EXHIBIT M
Case 1:17-mc-00025-RWS Document 10-13 Filed 06/30/16 Page 2 of 3
From: Jeffrey Pagliuca <jpagliuca@hmflaw.com>
Date: June 20, 2016 at 6:46:36 PM MDT
To: Meredith Schultz <mschultz@BSFLLP.com>, Laura Menninger <lmenninger@hmflaw.com>
Cc: Sigrid McCawley <Smccawley@BSFLLP.com>, Sandra Perkins <sperkins@BSFLLP.com>,
"'brad@pathtojustice.com' (brad@pathtojustice.com)" <brad@pathtojustice.com>
Subject: Re: 2016‐06‐17 Ltr to Menninger enc Giuffre005614‐Giuffre006279
It is unfortunate that you waited until the night before Detective Recarey’s deposition to dump all of this
discovery on me. I expect that you had this information for many years, indeed, Mr. Edwards is
mentioned in the discovery. I am not in a position to be able to adequately review it before the
deposition. I expect that means that we may need to keep the deposition open pending my review of
the documents.
Also, it appears to be a continuing problem that you list documents in your 26(a) disclosures but do not
produce them even though we make multiple requests for the documents. This behavior is prejudicial
and impeding out ability to adequately prepare for depositions and trial. Again, please produce all of
the documents listed in your 26(a) disclosures as required.
From: "Meredith com>" <mschultz@BSFLLP.com>
Date: Monday, June 20, 2016 at 6:57 PM
To: Laura Menninger <lmenninger@hmflaw.com>, Jeffrey Pagliuca <jpagliuca@hmflaw.com>
Cc: Sigrid McCawley <Smccawley@BSFLLP.com>, Sandra Perkins <sperkins@BSFLLP.com>,
"'brad@pathtojustice. com'" <brad@pathtojustice.com>
Subject: 2016‐06‐17 Ltr to Menninger enc Giuffre005614‐Giuffre006279
Counsel,
Please see the attached.
Thanks,
Meredith
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